Modern Day Slavery Policy
This statement is prepared in accordance with the requirements under the Modern Slavery Act 2018 and outlines the steps that PBS building has taken and is continuing to take to ensure that modern slavery or human trafficking is not taking place within our business or supply chain.
Modern slavery encompasses slavery, servitude, human trafficking and forced labour. PBS Building has a zero tolerance approach to any form of modern slavery and are committed to acting ethically and with transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the business or our supply chain.
PBS Building operates Construction Services in QLD, NSW and ACT. PBS’ team comprises of approximately 148 employees across these three States.
Policies and Governance Approach
PBS recognises the importance of protecting human rights and is committed to protecting the rights of all people including its employees, the communities in which PBS operates, those who may be impacted by its activities, its customers, and those within its supply chain.
PBS operates the enclosed policies that describe our approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in our operations:
- Our Values
- Recruitment Policy
- Whistleblower Policy
PBS Suppliers – Risk Detection and Management
We aim to undertake due diligence when considering taking on new suppliers and review our existing suppliers on a periodic basis. The due diligence process will be undertaken for each new supplier being set up as part of the ‘new supplier’ set up process. We have also commenced undertaking checks across our existing supplier base and will update these checks every 3 years. The due diligence checks include:
- Mapping the supply chain broadly to assess product or geographical risks of modern slavery and human trafficking.
- Evaluating the modern slavery and human trafficking risks of new suppliers.
- In addition, we are investigating the development of a reporting capability within our supplier database which will allow us to filter suppliers flagged as high risk and undertake our 3-year checks in a more efficient manner.
We do this by:
- Advising prospective suppliers during the tender process of our commitment to protecting human rights through statements in P14.03 Invitation to Tender Form and P14.11 Record of Tender Interview.
- Model clauses are included in our Subcontractor and Supplier Agreements.
- Identifying and assessing any risks in the supply chain as part of the P08.42 Design Safety Report & Review process.
We are in the process of developing training programs for employees to raise awareness of modern slavery issues. This would broadly be covering the below:
- The basic principles of the Modern Slavery Act 2018.
- How employers can identify and prevent slavery and human trafficking.
- What employees can do to flag up potential slavery or human trafficking issues to the relevant parties within the organization; and
- What external help is available, for example through the Modern Slavery Helpline.
Making a Report,Confidentiality and Privacy, and Investigation
We are taking steps to strengthen our supplier onboarding and monitoring processes to highlight modern slavery risk areas. The processes that we will implement include education of our supply chain to ensure these risks are adequately managed. Where suppliers are found to be non-compliant with our Standards of Business Conduct and contract terms requiring those suppliers to carry out remedial action, we will assist them to improve their processes.